United States v. Ronald Mitchell

788 F.2d 1232, 1986 U.S. App. LEXIS 24532
CourtCourt of Appeals for the Seventh Circuit
DecidedApril 16, 1986
Docket85-2005
StatusPublished
Cited by38 cases

This text of 788 F.2d 1232 (United States v. Ronald Mitchell) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Ronald Mitchell, 788 F.2d 1232, 1986 U.S. App. LEXIS 24532 (7th Cir. 1986).

Opinion

CUMMINGS, Chief Judge.

Ronald Mitchell appeals his conviction for “Bank Robbery and Incidental Crimes” under 18 U.S.C. § 2113(a) and (d), arguing that the trial court erred in permitting him to proceed pro se with standby counsel. Mitchell also challenges the trial court’s refusal to sever his trial from that of his co-defendant, its denial of his motion for judgment of acquittal, and his sentence of twenty years’ imprisonment. We affirm.

I.

This Court previously characterized the facts of Mitchell’s case in United States v. Oglesby, 764 F.2d 1273, 1274-75 (7th Cir. 1985), where we upheld the conviction of Mitchell’s co-defendant, Joseph Oglesby. The pertinent information is as follows:

The testimony at the trial of Oglesby and his co-defendant, Mitchell, in the United States District Court for the Southern District of Illinois established a bank robbery in Belleville, Illinois, and *1234 the subsequent arrest in East St. Louis, Illinois. At about noon on February 23, 1984, two men, later identified as Ogles-by and Mitchell, entered the Illini Federal Savings and Loan Association of Belle-ville, Illinois. While Mitchell approached the bank manager indicating that he wished to apply for a loan, Oglesby slipped behind the teller’s counter and pressed a loaded .38-caliber Derringer in the side of the nearest teller. Mitchell produced a .357 Magnum revolver and threatened the manager. At Oglesby’s direction, the teller removed $4,302.00 from the cash drawers and placed the money in a brown bag. Included in the money removed from the cash drawers was bait money, bills whose serial numbers were recorded for identification purposes. The removal of the bait money from the cash drawer activated the saving and loan’s surveillance cameras which took a series of pictures, including photographs of Oglesby and Mitchell, during the bank robbery.
After ordering their victims to lie face-down in a rear room of the bank, the two men fled in a yellow Camaro with Tennessee license plates. The two men drove to an apartment complex where they abandoned the Camaro and paid a Bernard Bolden $40.00 to drive them to a location in East St. Louis, Illinois. After leaving the men in East St. Louis, Bolden returned to the apartment complex where he was detained and questioned by the police. Bolden later accompanied the police to the East St. Louis address to which he had transported the men. The police located and apprehended the two subjects, searched the house where they were temporarily residing, and recovered a .38-caliber Derringer, a .357 Magnum Smith & Wesson revolver, and a large sum of money. The police removed one of the bait bills from Mitchell’s pockets and about $1,500.00 in cash.

On the first day of trial just before the jury was sworn, Mitchell requested the court to appoint him a new attorney. Because this request came so late, the court denied it and instead decided to allow him to proceed pro se with James Hackett, his appointed attorney, as standby counsel. Mitchell later submitted motions for severance and for a judgment of acquittal, both of which were denied. On April 25, 1984, the jury found Mitchell guilty of violating 18 U.S.C. § 2113(a) and (d), 1 and the court sentenced him to twenty years’ imprisonment. This appeal followed.

II.

We consider Mitchell’s four contentions in the order presented in his brief.

A. Pro se Representation.

Mitchell, after stating initially that he had irreconcilable differencies with Hack-ett, requested the district court to appoint him a new attorney. The court, refusing to delay the trial, urged Mitchell to accept the benefit of legal guidance, and it attempted *1235 to discuss with the defendant the potential problems of self-representation. 2 Mitchell chose to proceed pro se with Hackett as standby counsel rather than go to trial with Hackett as his regular attorney.

For Mitchell to knowingly and intelligently waive his Sixth Amendment right “to have the assistance of counsel for his defense,” he had to “be made aware of the dangers and disadvantages of self-representation so that he kn[ew] what he [was] doing and his choice [was] made with his eyes open.” Faretta v. California, 422 U.S. 806, 835, 95 S.Ct. 2525, 2541, 45 L.Ed.2d 562 (1975). See also McKaskle v. Wiggins, 465 U.S. 168, 104 S.Ct. 944, 79 L.Ed.2d 122 (1984); Edwards v. Arizona, 451 U.S. 477, 482-83, 101 S.Ct. 1880, 68 L.Ed.2d 378 (1981). While the trial judge need not give “a hypothetical lecture on criminal law,” Arnold v. United States, 414 F.2d 1056, 1058 (9th Cir.1969), cert. denied, 396 U.S. 1021, 90 S.Ct. 593, 24 L.Ed.2d 514 (1970), he should have more fully discussed the situation with Mitchell. Instead of stressing problems such as exclusion of evidence, self-incrimination, and waiver of potential defenses, the trial court merely mentioned that “there will be many occasions where possibly objections should be made that you will not recognize that should be made.” We do not, however, hold that this failure to inform Mitchell more completely about the dangers of waiving counsel rises to the level of reversible error, but this Court does caution district judges of the problems inherent in allowing criminal defendants to represent *1236 themselves without more complete warning. 3

Mitchell waited until the last minute before first requesting new counsel and then self-representation. Thus he could be asked, in the interest of orderly procedure, to choose between waiver of counsel and another course of action as long as the choice presented to him was not constitutionally offensive. United States v. Davis, 604 F.2d at 483 (quoting Maynard v. Mea-chum, 545 F.2d 273, 278 (1st Cir.1976)). In the present case, the court offered Mitchell with a clear choice between representation by Hackett or self-representation with Hackett available for consultation at the defendant’s discretion. The court indicated it was too near the start of the trial to appoint new counsel for Mitchell. In response, Mitchell persisted in his desire to proceed pro se.

The issue presented here is whether proceeding pro se with Hackett as standby counsel was a constitutionally adequate alternative to potentially ineffective assistance by Hackett’s complete representation by Mitchell.

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Bluebook (online)
788 F.2d 1232, 1986 U.S. App. LEXIS 24532, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-ronald-mitchell-ca7-1986.